4 Questions for...Antoine Vignial and Clara Ingen-Housz

Why do we talk about ethics and compliance at Saint-Gobain?

Antoine Vignial: Ethics and compliance are at the heart of our Principles of Conduct and Action. Adopted in 2003, these Principles act as our Group "constitution" and adhering to them is a condition to being a Saint-Gobain employee. Acting ethically in all circumstances and in compliance with our legal obligations is one of the fundamental values chosen and promoted by Saint-Gobain. It is therefore first and foremost a matter of corporate culture, upheld by each and every one of us: motivating and reassuring for our employees, attractive for our future recruits. They are also a key element of our Purpose.

Ethics and compliance also meet our stakeholders’ expectations. Our customers, suppliers, subcontractors, labor unions, shareholders, but also NGOs, communities and civil society expect multinationals to lead by example. Today, complying with the letter of the law is no longer considered sufficient: we must be able to do more and better, depending on our dialogue with stakeholders. Ethics and compliance are part of Business Ethics, one of the pillars of the Corporate Social Responsibility and which also covers our environmental initiatives.

Clara Ingen-Housz: Ethics and compliance are also here to protect employees, stakeholders and the Group itself. Indeed, it enables us to meet our international commitments such as the United Nations Global Compact and to comply with applicable laws around the world.

These include anticorruption laws, competition laws, economic sanctions and export control regulations. Beyond, our compliance with personal data regulations, the duty of vigilance law and its supply chain integrity requirements, or our human rights commitments, contribute to the same overarching objectives.

Who are the members of the Ethics and Compliance Department?

Antoine Vignial: Clara, in my team, leads the central team and works with the ethics and compliance officers in the countries or activities.

Clara: There is also a large network of Business Compliance Correspondents (BCCs) who contribute considerably to disseminating the compliance culture on the ground.

What does the Ethics and Compliance Department do?

Antoine Vignial: The Ethics and Compliance Department develops, deploys and implements the ethics and compliance program approved by Top Management. In carrying out its duties, it acts independently and impartially. This is critical to ensure the men and women who make up the department perform their mission effectively and without interference.

Clara Ingen-Housz: The Department is constantly in touch with the business and with other functions (HR, Finance, IT in particular). The program has several areas of focus: adoption of policies and procedures (such as the Anticorruption Policy), training (such as "Comply" in competition law), mapping our risks, in particular corruption risks, due diligence on third-party integrity and controls in the form of targeted audits. The Department also manages the ethics and professional alert system, which is now digital; the ethics and compliance officers act as Alert Examiners in charge of processing these alerts.

Do compliance and business go hand in hand? 

Antoine Vignial: While ethics and compliance concerns everybody, management plays an essential role. Managers at all levels are fully and personally committed to this issue. They communicate regularly on our principles and on the compliance program, and ensure that it is properly deployed. I would like to remind you that managers may, in many cases, be held legally liable for non-compliance within their perimeter.

In addition, unambiguous adherence to our values is a strong differentiator: leading by example in this area is crucial to our stakeholders. It enables us to strengthen the confidence of our business partners and attract talents, but also to improve investor perception, thus favoring our access to capital. As such, it does not in any way hinder the growth of our activities; on the contrary, it attracts to us partners who appreciate working with us and allows the Group to be a long-term player.

Clara Ingen-Housz: Given today’s proliferation of (often inconsistent) laws and regulations, the business-compliance partnership represents real added value. Indeed, if compliance may have been perceived as a hindrance, it is increasingly seen as a business partner in its own right, in two ways.

First, through its various areas of intervention (policies, targeted training), compliance helps operational staff to acquire the right behavior that protects them. Similarly, onboarding compliance in business projects early on helps identify or even quantify risks and provides concrete solutions. For example, in the field of mergers and acquisitions, compliance audits help to better value assets, or even to assess the feasibility of a transaction.

Second, with our ongoing digitalization of the compliance function, we work to ensure that checks are automatically embedded into the decision-making process (purchasing, sales, recruitment...), freeing up operational time by getting rid of many indispensable, even mandatory, but arduous and time-consuming tasks.

What are the priorities of the Ethics and Compliance Department in the coming months? 

Antoine Vignial: Transform & Grow has empowered the business through the Group's decentralization. Regarding ethics and compliance, our standards in this area are non-negotiable and we must speak with one and only one voice: it is therefore a Red Zone!  The Department will therefore carry on consolidating and continuously adapting the existing program, and will rely, for its deployment, on the strong commitment of all managers, both operational and functional as powerful transmission levers.

We will also collect and use more and more data to better inform our decisions, improve our organization, and showcase our performance in terms of business ethics to our stakeholders.

Clara Ingen-Housz: Our new Group Anticorruption Policy, recently approved by the Executive Committee, will be the subject of an extensive communication and training plan, including short videos explaining and illustrating various corruption scenarios. At the same time, we will continue our information and awareness campaign on our new digital alert system to ensure that it is fully understood by everyone and thus, truly effective.

More generally, we are also engaged in a vast digitalization campaign for the ethics and compliance function, which will facilitate and secure many processes such third-party due diligence and reporting of gifts/invitations and conflicts of interest.

Last but not least, we look forward to the first edition of the Principles of Conduct and Action Day in June 2021 - a day dedicated to the interplay between compliance, personal data, responsible purchasing and more generally, Corporate Social Responsibility. This day will be a further opportunity to present and raise awareness of Business Ethics among all the Group's employees.